France-Monaco tax treaty: what the 1963 text says

The convention of May 18, 1963, between France and Monaco is not a double taxation agreement in the usual sense. Article 7-1 stipulates that French nationals who have transferred their domicile or residence to Monaco are subject to French income tax under the same conditions as if they were domiciled or resident in France, with a second provision based on the convention of October 13, 1962. For a French client, this is generally the rule to consider before any relocation project: the BOFiP (Official Bulletin of Public Finances) lists exceptions. This page presents the text and its limitations.

Dates to know

The BOFiP (Official Bulletin of Public Finances) presents the 1963 agreement as intended to replace the former neighborhood and mutual administrative assistance agreement. The 2003 exchange of letters extends Article 7 to the wealth tax (ISF). The official list of agreements (BOI-ANNX-000306) cites other instruments: exchanges of letters (1966, 1971, 2010), the content of which is not presented here, and an agreement of February 25, 2019, concerning gifts and bequests made to public entities and non-profit organizations, unrelated to Article 7-1. Further details can be found in the texts themselves, published by the tax authorities.

An unusual convention

France's official list of tax treaties (BOI-ANNX-000306) includes Monaco among the treaties "not primarily intended to avoid double taxation".

For reading purposes, this page focuses on Article 7, which is relevant for French citizens: the provisions by income category and the maximum rates of a classic convention are not presented here.

Article 7-1: French citizens residing in Monaco

According to the French tax authorities (BOFiP, BOI-INT-CVB-MCO-10), French nationals who have transferred their domicile or residence to Monaco are "subject to French income tax under the same conditions" as if they had their domicile or residence in France. The practical effect is straightforward: a French citizen who moves to Monaco does not, in principle, escape French income tax.

The text of the convention (article 7, paragraph 1) has a second part: it also covers persons who cannot prove five years of habitual residence in Monaco on October 13, 1962. The PDF of the convention and the BOFiP use the same date and the same duration; only their wording differs.

The Monegasque Government says the same thing: there is no personal income tax in Monaco, "with the exception of French nationals governed by the Franco-Monegasque bilateral Convention of 1963".

Regarding exit tax, the instructions for form 2074-ETD (transfers in 2025) state that, for those with French nationality, transferring their residence to the Principality of Monaco does not constitute a transfer of tax residence outside of France. Our page "Leaving France for Monaco" explains this point and its limitations.

Convention and French tax residence

Tax residence in France is determined primarily based on three alternative criteria outlined in Article 4 B of the French General Tax Code (CGI), as explained in the Official Bulletin of Public Finances (BOFiP) (BOI-IR-CHAMP-10): the home or principal residence, the principal professional activity carried out in France, and the center of economic interests. Only one of these criteria needs to be met. An actual presence in France for more than six months of the year creates a presumption of principal residence, although this is not an absolute criterion.

For a French citizen settling in Monaco, these criteria and Article 7-1 of the convention should be considered together. How they interact in your specific case is a point that needs to be examined in detail, along with the relevant legal texts.

Exceptions, social contributions and IFI

• Exceptions do exist. The BOFiP lists the relevant categories in paragraphs 30 to 110, for example, for French citizens residing in Monaco before October 13, 1957, the Sovereign House, or persons married to a Monegasque citizen. These categories are not detailed here; they can be found in the BOFiP and the text.
• The CSG and the CRDS. The BOFiP (§ 230) indicates that article 7-1 only relates to income tax; the CSG and CRDS may apply by operation of article 4 B of the CGI.
• The IFI. The 2003 exchange of letters extended Article 7 to the wealth tax (ISF). According to the French Official Tax Bulletin (BOFiP, paragraphs 380 to 390), Article 7-3 subjects French citizens who transferred their tax residence to Monaco on or after January 1, 1989, to the real estate wealth tax (IFI) on all their real estate assets included in the tax base; for those who settled there before then, only assets located in France are subject to the IFI. The text of Article 7, paragraph 3, should be read before applying this rule.
• The doctrine. The version of the BOFiP dedicated to Monaco dates from June 2, 2021.

La convention multilatérale (MLI)

The convention with Monaco is included in the list of conventions amended by the multilateral convention (BOI-ANNX-000511). The dates of entry into force in France are as follows.

The consolidated text published by the administration shows notes to the multilateral convention on the preamble, on a clause entitled "Right to the Benefits of the Convention" placed before Title I, and on Articles 24 and 26. Article 7 remains unchanged. The BOFiP (Official Bulletin of Public Finances) dedicated to Monaco does not mention the MLI (Multilateral Investment Agreement).

Inheritance: a separate agreement

Inheritance is governed by a separate text: the Convention of April 1, 1950, on Succession. According to Article 2, real estate and real property rights forming part of the estate of a national of one of the two states are subject to inheritance tax only in the state where they are located. The rules applicable to securities or the deceased's domicile are not presented here. Our "Living in Monaco" page provides the Monegasque tax rates for properties located in Monaco.

How to read these texts

The 1963 convention is available in PDF format on impots.gouv.fr. The BOFiP (Official Bulletin of Public Finances) provides commentary on it in the BOI-INT-CVB-MCO series. The list of conventions (BOI-ANNX-000306) and the list of the multilateral convention (BOI-ANNX-000511) are kept up to date by the tax authorities. Before deciding to change your tax residence, you should read all three sources in their entirety.

What changes depending on your situation

• Your nationality: Article 7-1 refers to persons of French nationality.
• The date of your arrival in Monaco and the duration of your residence: the text refers to this, and its rules are not detailed here.
• The nature of your income and assets: CSG, CRDS and IFI depend on your date of installation and the criteria of article 4 B.
• The location of your assets: this determines the applicable inheritance agreement.
• A previous contribution-sale: the effect of a departure to Monaco on the carry-forward is examined before the departure.

These points are examined on a case-by-case basis. No result can be announced without this examination.